OFAC screening for digital wallets
Digital wallet providers, from Apple Pay to crypto wallets, hold funds and must screen the parties behind them.
TL;DR
TL;DR: Digital wallet providers such as Apple Pay, Google Pay, and crypto wallets must screen transactions and counterparties for sanctions, because the wallet is the point where value moves.
Why wallets are on the hook
A wallet holds and moves customer funds. When a sanctioned party funds or withdraws through a wallet, the provider is the party moving value to or from a blocked person. Strict liability means the provider cannot defend on the basis of not knowing the customer's status.
What to screen
- Counterparty names against 19,218 SDN names.
- Wallet addresses against 947 OFAC-listed crypto wallets.
- Jurisdiction across 16 tracked regions.
- Both funding and withdrawal events.
How to fit it in
sanctionsai.dev screens in under 100 ms, fast enough to run inside a funding or withdrawal flow. It returns ALLOW for clean and BLOCK for flagged, and integrates with x402, MCP, and Base/USDC payment stacks.